April 20, 2015

Federal Aviation Administration:

On behalf of Osprey Assessments LLC we would like to formally submit for an exemption from part 21, subpart H; and Sections 45.23(b), 91.7(a), 91.9(b)(2), 91.119, 91.121,

91.151(a), 91.203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and

(b) of Title 14, Code of Federal Regulations (14 CFR). This proposed exemption would

allow our operation of unmanned aircraft systems (UAS) for the purpose of UAV based

photo, video, thermography, LiDAR and integrated software control and capture systems to conduct façade and roof condition assessments of multi-story buildings and agriculture areas.

We will operate a UAS, the DJI S1000+, which is comprised of an unmanned aircraft, an

attached camera and a transportable ground station.

The DJI S1000+ is an octocopter with a maximum gross weight of about 24 pounds. It is

equipped with eight rotors that are driven by electric motors powered by batteries. The

UA has a maximum airspeed of approximately 40 knots. We will operate the UA in various metropolitan and rural areas across the US.

UAS Operating Parameters

We will abide by the following additional operating conditions under this exemption:

• operate UAS within a 100 foot envelope of the building being assessed or below 400

feet AGL, whichever is greater, and within radius distance of 1000 feet from the controller to aid in direct line of sight visual observation;

• obtain permission from the owner/controller of any vessels, vehicles and structures

when operations may be conducted closer than 500 feet to any such vessels, vehicles

or structures; we will conduct a safety assessment of the risk of operating closer to

those objects and determine that it does not present an undue hazard;

• operate at all times with an automatic emergency recovery system, equal to or better

than the DJI Dropsafe parachute recovery system, that is installed and armed;

• operate the UAS for 10-20 minutes per flight;

• land UAS prior to the manufacturer’s recommended minimum level of battery power;

• operate UAS within visual line of sight (VLOS);
• use the UAS’ global positioning system (GPS) flight safety feature whereby it hovers

and then slowly lands if communication with the remote control pilot is lost;

• contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;

• always obtain all necessary permissions prior to operation;

• have procedures in place to abort flights in the event of safety breaches or potential

danger (reference “DJI S1000+ Pilot Operating Handbook” provided);

• conduct extensive preflight inspections and protocols, during which safety carries primary importance (reference “DJI S1000+ Pilot Operating Handbook” provided).

UAS Pilot in Command (PIC)

The PIC will hold either an airline transport, commercial, private, recreational or sport

pilot certificate. The PIC will also hold a current FAA airman medical certificate or a

valid US driver’s license.

All PICs will demonstrate the ability to safely operate the UAS in a manner consistent

with how the UAS will be operated under the requested exemption, including evasive

and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

Specific Exemptions Requested

Given the size, weight, speed, and limited operating area associated with the UA, we

feel an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and §

91.203(a) and (b) (Certifications required), subject to certain conditions and limitations,

is warranted and meets the requirements for an equivalent level of safety under 14 CFR

part 11 and Section 333 of P.L. 112-95 (Section 333).

We request an exemption from § 45.23 Marking of the aircraft because the UA will not

have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further,

the two-inch lettering is difficult to place on such a small aircraft with dimensions smaller

than the minimal lettering requirement. Regardless of this, we can mark the UAS in the

largest possible lettering by placing the word “Experimental” on its fuselage as required

by § 45.29(f) so that anyone will see the markings.

We request an exemption from § 91.7(a) which prohibits the operation of an aircraft

without an airworthiness certificate, since there is currently no certificate applicable to

our operation, this regulation is inapplicable.
We request an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a)

and (b) Maintenance inspections since they only apply to aircraft with an airworthiness

certificate. However, as a safety precaution we will perform a preflight inspection of the

UAS before each flight as outlined in the attached operating documents.

We request an exemption from § 91.9(b)(2) which requires an aircraft flight manual in

the aircraft, however since there are no pilots or passengers on board the aircraft and

given its size, this regulation is inapplicable. We believe an equivalent level of safety

will be achieved by maintaining a safety/flight manual with the UAS ground station.

We request an exemption from § 91.119 which prescribes safe altitudes for the operation of civil aircraft, but it allows helicopters to be operated at lower altitudes in certain

conditions. We will operate the UAS within a 100 foot envelope of the building being assessed, or below 400 feet AGL, whichever is greater.

We request an exemption from § 91.121 Altimeter settings as it is inapplicable since the

UAS utilizes electronic GPS with a barometric sensor.

We request an exemption from § 91.151(a) Fuel requirements for flight in VFR conditions. The UAV is 100% electric and two low battery alerts are issued - per the operating documents, the UAV will be landed at the first alert. Also, our flights will last only 5-

20 minutes each, and the UAS has an automated function which results in immediate

landing when a low battery is detected. The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly to the first point

of intended landing and, assuming normal cruising speed, land the UA with 30% battery

power remaining.

Business and Public Interest

Ground and suspended scaffold based photo, video, thermography and LiDAR assessments have been around for some time, but can be cost-prohibitive and time consuming. In the case of operations from suspended scaffold stages and Boatswains' chairs

are inherently risky and governed by OSHA Fall Protection regulations. By granting this

exemption we would be able to provide this service at a much lower risk profile, both for

inspectors and the public, lower cost and with greater efficiency. Further, our small UAS

will pose no threat to the public given its small size, automatic emergency recovery system and lack of combustible fuel when compared to larger manned aircraft.

Summary

We will comply with all of the following conditions and limitations should this grant of exemption be provided:
1) Operations will be limited to the following aircraft described in the operating documents which is an octocopter aircraft weighing less than 24 pounds: DJI S1000+ Unmanned Aircraft System.

2) The UA will be operated at all times with an automatic emergency recovery system,

equal to or better than the DJI Dropsafe parachute recovery system, that has been inspected, installed and armed prior to each flight.

3) The UA will not be flown at an airspeed exceeding 40 knots.

4) The UA will be operated within a 100 foot envelope of the building being assessed or

below 400 feet AGL, whichever is greater, and within radius distance of 1000 feet from

the controller to aid in direct line of sight visual observation.

5) The UA will be operated within visual line of sight (VLOS) of the Pilot In Command

(PIC) at all times.

6) All operations will utilize a visual observer (VO). The UA will be operated within the

visual line of sight (VLOS) of the VO at all times. The VO and PIC will be able to communicate verbally at all times. The PIC will be designated before the flight and will not

transfer his or her designation for the duration of the flight. The PIC will ensure that the

VO can perform the functions prescribed in the operating documents.

7) The operating documents will be accessible during UAS operations and made available to the Administrator upon request. Any revisions to the operating documents will be

presented to the Administrator upon request.

8) Prior to each flight, the PIC will inspect the UAS to ensure it is in a condition for safe

flight. If the inspection reveals a condition that affects the safe operation of the UAS, the

UAS will not be operated until the necessary maintenance has been performed and the

UAS is found to be in a condition for safe flight. The Ground Control Station will be included in the preflight inspection. All maintenance and alterations will be properly documented in the aircraft records.

9) Any UAS maintenance or alterations that affect the UAS operation or flight characteristics, e.g. replacement of a flight critical component, will undergo a functional test flight.

The PIC who conducts the functional test flight will make an entry in the aircraft records.

10) The pre-flight inspection section in the operating documents will account for all discrepancies, i.e. inoperable components, items, or equipment, not already covered in the

relevant sections of the operating documents.
11) We will follow the UAS manufacturer’s aircraft/component, maintenance, overhaul,

replacement, inspection, and life limit requirements.

12) We will carry out maintenance, inspections, and record keeping requirements, in accordance with the operating documents. Maintenance, inspection, and alterations will be

noted in the aircraft records, including total flight hours, description of work accomplished, and the signature of the authorized person returning the UAS to service.

13) Each UAS operated will comply with all manufacturer Safety Bulletins.

14) An authorized person will make an entry in the aircraft record of the corrective action taken against discrepancies discovered between inspections.

15) UAS operations will be conducted by a PIC possessing at least a private pilot certificate and at least a current third-class medical certificate or a valid US driver’s license.

16) Prior to operations conducted for the purpose of this exemption, the PIC will demonstrate then ability to safely operate the UAS, including evasive and emergency maneuvers and maintaining appropriate distances from persons, vessels, vehicles and structures.

17) The UA will not operate within 5 nautical miles of an airport reference point as denoted on a current FAA-published aeronautical chart, unless a letter of agreement with

that airport’s management is obtained or otherwise permitted by a COA issued.

18) The UA will not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when visibility is less than 3 statute miles from the PIC.

19) If a UA loses communications or loses its GPS signal, it will return to a predetermined location within the planned operating area and land or be recovered in accordance with the operating documents.

20) The PIC will abort a flight in the event of unpredicted obstacles or emergencies in

accordance with the operating documents.

21) The PIC will not begin a flight unless (considering wind and forecast weather conditions) there is enough power to fly at normal cruising speed to the intended landing

point and land the UA with 30% battery power remaining.

22) Before conducting operations, the radio frequency spectrum used for operation and

control of the UA will comply with the Federal Communications Commission (FCC) or

other appropriate government oversight agency requirements.
23) The documents required under 14 CFR 91.9 and 91.203 will be available to the PIC

at the Ground Control Station of the UAS any time the UAS is operating. These documents will be made available to the Administrator or any law enforcement official upon

request.

24) The UA will remain clear and yield the right of way to all manned aviation operations

and activities at all times.

25) The UAS will not be operated by the PIC from any moving device or vehicle.

26) The UA will not be operated over congested or densely populated areas without an

inspected, armed and operational emergency recovery system rated for the maximum

gross weight of the UAS.

27) Flight operations will be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless:

a. Barriers or structures are present that sufficiently protect nonparticipating persons

from the UA and/or debris in the event of an accident. We will ensure that nonparticipating persons remain under such protection. If a situation arises where nonparticipating

persons leave such protection and are within 500 feet of the UA, flight operations must

cease immediately and/or;

b. The owner/controller of any vessels, vehicles or structures has granted permission for

operating closer to those objects and the PIC has made a safety assessment of the risk

of operating closer to those objects and determined that it does not present an undue

hazard.

28) All operations will be conducted over private or controlled-access property with permission from the land owner/controller or authorized representative. Permission from

land owner/controller or authorized representative will be obtained for each flight to be

conducted.

28) Any incident, accident, or flight operation that transgresses the lateral or vertical

boundaries of the operational area as defined by the applicable COA will be reported to

the FAA's UAS Integration Office (AFS-80) within 24 hours. Accidents will be reported to

the National Transportation Safety Board (NTSB) per instructions contained on the

NTSB Web site: www.ntsb.gov.